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    GAO: Clearer Guidance on Student Privacy Requirements Is Needed

    In a new report (pdf), “Postsecondary Education: Many States Collect Graduates’ Employment Information, but Clearer Guidance on Student Privacy Requirements Is Needed,” the Government Accountability Office finds that states are having problems determining acceptable use and collection practices for postsecondary education and employment data under the Family Educational Rights and Privacy Act (FERPA).

    The data collected in state databases on students can include: “basic demographic and enrollment data such as name, gender, ethnicity, major, degree granted, and academic history and financial aid information such as family income, expected family contribution, and financial assistance from state, federal, and other sources.”

    One challenge cited by several state officials we interviewed was how to link postsecondary graduate student and employment data without violating student privacy requirements under FERPA. Linking student and employment data could entail sharing student records with entities outside education agencies, such as labor agencies, which in turn could violate FERPA. While FERPA may allow for the nonconsensual disclosure of personally identifiable information from student records with state educational agencies, as long as it is for a purpose permitted under one of FERPA’s exceptions, such as for program evaluation to improve instruction, it does not explicitly address the nonconsensual disclosure of personally identifiable information from education records to a state department of labor for the purpose of linking student and employment records or how these linkages could be performed. Consequently, some states have been unwilling to link their education data systems to labor data. 

    Officials in Colorado and Michigan—states not linking education data to UI wage records—cited FERPA as a roadblock to their states’ efforts to develop a comprehensive database that follows students after graduation. Moreover, the SHEEO report found that over half of states cited FERPA as a barrier to linking postsecondary data systems with labor data. […]

    On the basis of our review of relevant literature and interviews with numerous state officials and subject matter experts, we identified several potential approaches for expanding the collection of postsecondary graduates’ employment information on a broad level, such as across states or nationwide. These include direct state-to-state or regional data-sharing arrangements, using third parties to assist state efforts in a variety of ways, and expanded national surveys that collect employment-related data.

    Each approach presents challenges. Regardless of how collection efforts might expand, many state officials and other stakeholders we spoke to emphasized the importance of having a clear understanding of the specific policy questions that the data system should address prior to creating it. For example, state officials in Colorado noted that when the policy questions are known, it makes determining the required data elements needed to answer those questions easier and can decrease unnecessary data collection and costs.

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